Preferred Options consultation document
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Preferred Options consultation document
Minerals Strategic Objectives
Representation ID: 94854
Received: 28/10/2019
Respondent: Cemex UK Materials Ltd
MSO1 could be made a more effective statement by making specific reference to what the steady and adequate supply of aggregate minerals actually consists of. This could be achieved by including within the policy a specific reference to guidance provided by paragraph 207f of NPPF, i.e., providing a steady and adequate supply of aggregate minerals through the provision of "... at least a 7 year landbank for sand and gravel...).
MSO1 could be made a more effective statement by making specific reference to what the steady and adequate supply of aggregate minerals actually consists of. This could be achieved by including within the policy a specific reference to guidance provided by paragraph 207f of NPPF, i.e., providing a steady and adequate supply of aggregate minerals through the provision of "... at least a 7 year landbank for sand and gravel...).
Object
Preferred Options consultation document
Biodiversity and Geological Conservation
Representation ID: 94859
Received: 28/10/2019
Respondent: Cemex UK Materials Ltd
Paragraphs 8.18 to 21 do not appear to explicitly distinguish between the hierarchy of international, national and locally designated sites as advised by paragraph 171 of NPPF. These paragraphs should be revised to accomodate this guidance, else, in the view of the Company, be found unsound.
Paragraphs 8.18 to 21 do not appear to explicitly distinguish between the hierarchy of international, national and locally designated sites as advised by paragraph 171 of NPPF. These paragraphs should be revised to accomodate this guidance, else, in the view of the Company, be found unsound.
Object
Preferred Options consultation document
Historic Environment
Representation ID: 94865
Received: 28/10/2019
Respondent: Cemex UK Materials Ltd
Paragraph 189 of NPPF states that: -
"The level of detail should be proportionate to the assets' importance and no more than is sufficient to understand the potential impact of the proposal on their significance."
This guidance does not appear to have been accounted for in paragraphs 2,28 to 30, nor has any justification as to why Norfolk should deviate from it been provided. These paragraphs should be amended to accomodate NPPF guidance provided by paragraph 189 or the text be found unsound.
Paragraph 189 of NPPF states that: -
"The level of detail should be proportionate to the assets' importance and no more than is sufficient to understand the potential impact of the proposal on their significance."
This guidance does not appear to have been accounted for in paragraphs 2,28 to 30, nor has any justification as to why Norfolk should deviate from it been provided. These paragraphs should be amended to accomodate NPPF guidance provided by paragraph 189 or the text be found unsound.
Comment
Preferred Options consultation document
Policy MW3: Transport
Representation ID: 94867
Received: 28/10/2019
Respondent: Cemex UK Materials Ltd
Whilst measures to reduce car usage are both lauable and supported, it is the Company's experience that due to the often remote location of its facilities and a corresponding lack of public transport plus the geographical distribution of its employees this can be difficult to achieve. To reflect this, it is felt that the last bullet point of this poicy should be caveated by the phrase "where practicable...".
Whilst measures to reduce car usage are both lauable and supported, it is the Company's experience that due to the often remote location of its facilities and a corresponding lack of public transport plus the geographical distribution of its employees this can be difficult to achieve. To reflect this, it is felt that the last bullet point of this poicy should be caveated by the phrase "where practicable...".
Object
Preferred Options consultation document
Policy MW4: Climate change mitigation and adaption
Representation ID: 94869
Received: 28/10/2019
Respondent: Cemex UK Materials Ltd
See comments regards Policy MW3 with regard to Policy MW4f.
Whilst measures to reduce car usage are both lauable and supported, it is the Company's experience that due to the often remote location of its facilities and a corresponding lack of public transport plus the geographical distribution of its employees this can be difficult to achieve. To reflect this, it is felt that the last bullet point of this policy should be caveated by the phrase "where practicable...".
See comments regards Policy MW3 with regard to Policy MW4f.
Whilst measures to reduce car usage are both lauable and supported, it is the Company's experience that due to the often remote location of its facilities and a corresponding lack of public transport plus the geographical distribution of its employees this can be difficult to achieve. To reflect this, it is felt that the last bullet point of this policy should be caveated by the phrase "where practicable...".
Object
Preferred Options consultation document
Policy MP1: Provision for minerals extraction
Representation ID: 94878
Received: 28/10/2019
Respondent: Cemex UK Materials Ltd
As currently worded it is not clear that this policy is commited to maintaining a sufficient sand and gravel landbank for the entire Plan period, i.e., a landbank of at least 7 years will still remain in place at the end of the Plan period. It is suggested that by adding the phrase "...throughout the Plan period" after reference within the policy to "...at least 7 years' supply..." this potential ambiguity would be resolved.
As currently worded it is not clear that this policy is commited to maintaining a sufficient sand and gravel landbank for the entire Plan period, i.e., a landbank of at least 7 years will still remain in place at the end of the Plan period. It is suggested that by adding the phrase "...throughout the Plan period" after reference within the policy to "...at least 7 years' supply..." this potential ambiguity would be resolved.
Comment
Preferred Options consultation document
Policy MP10: safeguarding of port and rail facilities, and facilities for the manufacture of concrete, asphalt and recycled materials
Representation ID: 94882
Received: 28/10/2019
Respondent: Cemex UK Materials Ltd
The policy does not make explicit reference to the use of such facilities for the handling of prmary aggregate. It should be revised to include facilities that handle primary materials are also safeguarded.
The policy does not make explicit reference to the use of such facilities for the handling of prmary aggregate. It should be revised to include facilities that handle primary materials are also safeguarded.
Support
Preferred Options consultation document
Specific Site Allocation Policy MIN 202 (Attlebridge)
Representation ID: 94888
Received: 28/10/2019
Respondent: Cemex UK Materials Ltd
The Company supports the inclusion of this policy, and both notes and particularly supports paragraph 202.5, which is considered to reflect the proportionate approach to archaeology advocated by paragraph 189 of NPPF.
The Company supports the inclusion of this policy, and both notes and particularly supports paragraph 202.5, which is considered to reflect the proportionate approach to archaeology advocated by paragraph 189 of NPPF.
Support
Preferred Options consultation document
Specific Site Allocation Policy MIN 213 (Stratton Strawless)
Representation ID: 94892
Received: 28/10/2019
Respondent: Cemex UK Materials Ltd
The Company supports the inclusion of the policy in the Plan.
The Company supports the inclusion of the policy in the Plan.
Support
Preferred Options consultation document
MIN 71 - land west of Norwich Road, Holt
Representation ID: 94896
Received: 28/10/2019
Respondent: Cemex UK Materials Ltd
The Company objects the the exclusion of this site from the Plan. The landowner has indicated that they are prepared to see the site worked as an extension to CEMEX's Holt Quarry, and is in the process of securing this indication is writing. As an extension to Holt Quarry as opposed to a stand-alone operation, it is felt that the objections to the site as a Specific Site for Aggregate extraction can be overcome.
The Company objects the the exclusion of this site from the Plan. The landowner has indicated that they are prepared to see the site worked as an extension to CEMEX's Holt Quarry, and is in the process of securing this indication is writing. As an extension to Holt Quarry as opposed to a stand-alone operation, it is felt that the objections to the site as a Specific Site for Aggregate extraction can be overcome.
